In Revenue Procedure 2020-44, the United States (US) Internal Revenue Service (IRS) confirmed that certain fallback language modifying debt instruments, derivatives, and other financial contracts to cover the possible discontinuance of the London Interbank Offered Rate (LIBOR) will not cause a deemed taxable exchange for US federal income tax purposes. The confirmation also applies to other “interbank offered rates” (IBORs), such as the Euro Interbank Offered Rate (EURIBOR). In addition, the IRS confirmed that the modifications will not change the tax treatment of a “synthetic” debt instrument (i.e., an integrated debt instrument and hedge under Treas. Reg. Sections 1.988-5 or 1.1275-6).The...